MOTION FOR JUDGMENT ON COMPROMISE
COME now the petitioner and the respondent, Vicente B. Pichon, assisted by their respective attorneys and unto the Honorable Supreme Court, most respectfully allege:
1. That the parties hereto agree as they have agreed to terminate the above-entitled case, through a compromise agreement, under the following terms and conditions, to wit:
(a) The petitioner admits the legality and validity of the Deed of Sale, dated January 10, 1972, particularly denominated as Doc. No. 79; Page No. 17; Book No. 31; Series of 1972, executed before Notary Public, Severo C. Medina, and subject of litigation this case;
(b) The respondent in consideration of the said admission of the validity and legality of said document of sale, hereby waives all his rights, claims and other monetary demands he has against the petitioner from documents, checks and promissory notes which has (sic) come into his possession and binds himself to immediately, upon the signing of this agreement, return the possession thereof as his sign of good faith;
(c) The parties hereby mutually waive all their rights to file any case, arising from incidents connected with the above-entitled case, and they hereby also waive their rights and consider terminated and closed that Civil Case No. 7421 which is still pending before the Court of First Instance of Davao, Branch 11, which respondent has filed against the petitioner for the collection of sum of money;
(d) The parties hereto in order to give due effects to the Deed of Sale, dated January 10, 1972, and denominated as Doc. No. Page No. 17: Book No. 31; Series of 1972, and executed before Notary Public Severo C. Medina and individual titles would be issued in their respective names by the Register of Deeds of Davao City, bind themselves to consider cancelled, null and void and without any effect the notices of lis pendens and/or adverse claims they have respectively filed with the Register of Deeds of Davao City, over the parcels of land described in TCT No. T-20681.
WHEREFORE, it is respectfully prayed that the herein compromise agreement be approved and the same be made the basis of any decision that may be issued by the Honorable Supreme Court in the above-entitled case.
Davao City (for Manila), Philippines, September 7, 1978.
(Sgd.) VICENTE B. PICHON (Sgd.) HUANG SIU SIN Respondent Petitioner
ASSISTED BY: ATTY. VICTORIO S. ADVINCULA Davao City and ATTY. FRANCISCO A. VILLA 2nd Floor, Tasco Bldg. ATTY. ARTURO MOJICA 5486 South Superhighway 310 Burke Bldg. Metro Manila Escolta, Manila and ATTY. JOSE R. MADRAZO, JR. By: 2nd Floor, Villa Abrille Bldg. C. M. Recto St., Davao City (Sgd.) VICTORIO S. ADVINCULA By: (Sgd.) JOSE R. MADRAZO, JR. *
